Settlement Agreement

SETTLEMENT AGREEMENT AND RELEASE
THIS SETTLEMENT AGREEMENT AND RELEASE ("Settlement Agreement") is

entered into between StarkHR Consulting LLC (hereinafter "Plaintiff"), and Vistajet
US Inc. (hereinafter "Defendant").
RECITALS
A. StarkHR Consulting LLC filed a lawsuit against Vistajet US Inc.
B. The parties desire to enter into this Settlement Agreement in order to resolve
the dispute and provide for certain payments in full settlement and discharge of
all claims which are or might become the subject of the lawsuit, upon the terms
and conditions set forth herein.
AGREEMENT
The parties hereto agree as follows:
1. Release and Discharge
In consideration of Defendant's agreement to make the payments called for
herein, StarkHR Consulting LLC completely releases and forever discharges
Vistajet Group Holding SA, of and from any and all past, present, or future
claims, demands, obligations, actions, causes of action, rights, damages, costs,
loss of services, expenses, and compensation which StarkHR Consulting LLC
now has, or which may hereafter accrue or otherwise be acquired by StarkHR
Consulting LLC, on account of, or in any way growing out of the lawsuit.
2. Consideration
In consideration of the release set forth above, Defendant hereby agrees to pay
StarkHR Consulting LLC fifteen million dollars ($15,000,000.00). Out of this total
settlement amount, five hundred thousand dollars ($500,000.00) shall be
allocated to each of the eight passengers affected by the lack of transportation,
namely:
- Cristine Sauter
- Gabriel Luiz Sauter Ricciarelli
- Anne Marie Sauter Ricciarelli
- Daniel Luiz Sauter Ricciarelli
- Louise Marie Sauter Ricciarelli
- Kian Tochio Schurmann
- João Mellão Alves de Lima Romanini
- Caetano Simioni Rey Siqueira
Defendant further agrees not to engage in any actions or omissions that may
cause harm or inconvenience to StarkHR Consulting LLC or its affiliates or any of
the affected passengers.
3. Payment Terms
a. The total settlement amount of fifteen million dollars ($15,000,000.00) shall be
paid by Vistajet US Inc. to StarkHR Consulting LLC within 5 (five) business days
of the execution of this Settlement Agreement.
b. Prior to disbursing any payments to StarkHR Consulting LLC or the individual
passengers, Vistajet US Inc. shall deduct the agreed-upon attorney's fees directly
from the total settlement amount. The attorney's fees shall be paid directly to the
legal representatives of StarkHR Consulting LLC as follows:
[Attorney's Firm Name]

[Attorney's Firm Address]
[Attorney's Firm Contact Information]
c. The remaining balance after deducting the attorney's fees shall then be
allocated as follows:
For each of the eight passengers affected by the lack of transportation, the
settlement amount shall be five hundred thousand dollars ($500,000.00) minus
the legal fees incurred by StarkHR Consulting LLC on behalf of each passenger.
The adjusted settlement amount shall be paid directly to each passenger within 5
(five) business days of the receipt of the total settlement amount by StarkHR
Consulting LLC.
d. The remainder of the settlement amount, after deducting legal fees and
payments to passengers, shall be paid to StarkHR Consulting LLC.
[StarkHR Consulting LLC Bank Account Details]
Bank Name:
Account Name:
Account Number:
ABA/Routing Number:
Swift Code (if applicable):
[Individual Passenger Bank Account Details]

[Insert Bank Account Details for Each Passenger Receiving Compensation]
4. Attorneys' Fees
Each party hereto shall bear its own attorneys' fees and costs arising from the
actions of its own counsel in connection with the Demand and this Settlement
Agreement and incurred prior to the date of execution of the Agreement. In any
action of any kind relating to this Agreement, the prevailing party shall be entitled
to collect reasonable attorneys' fees and costs from the non-prevailing party in
addition to any other recovery to which the prevailing party is entitled.
5. Warranty of Capacity to Execute Agreement

The Plaintiff represents and warrants that no other person or entity has or has
had any interest in the claims, demands, obligations, or causes of action referred
to in this Settlement Agreement, except as otherwise set forth herein, and that it
has not sold, assigned, transferred, conveyed or otherwise disposed of any of the
claims, demands, obligations, or causes of action referred to in this Settlement
Agreement.
6. Entire Agreement and Successors in Interest

This Settlement Agreement contains the entire agreement between the Plaintiff
and the Defendant with regard to the matters set forth herein and shall be binding
upon and inure to the benefit of the executors, administrators, personal
representatives, heirs, successors and assigns of each.
7. Representation of Comprehension of Document

In entering into this Settlement Agreement, the Plaintiff represents that it has
relied upon the legal advice of its attorneys, who are the attorneys of its own
choice and that the terms of this Settlement Agreement have been completely
read and explained to it by its attorneys, and that those terms are fully
understood and voluntarily accepted by it.
8. Governing Law
This Settlement Agreement shall be construed and interpreted in accordance
with the laws of the State of New York.
9. Additional Documents
All parties agree to cooperate fully and execute any and all supplementary
documents and to take all additional actions which may be necessary or
appropriate to give full force and effect to the basic terms and intent of this
Settlement Agreement.
10. Effectiveness
This Settlement Agreement shall become effective on execution.
Dated: __________________ __________________________

Cristine Sauter
CEO of StarkHR Consulting LLC
Plaintiff
Dated: _________________ __________________________
By: __________________________
Vistajet US Inc.
The foregoing release was explained to Plaintiff and executed in accordance with
our directions and advice.
ROBB & ROBB LLC
Dated: _________________ By:_________________________

Settlement Agreement

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SETTLEMENT AGREEMENT AND RELEASE

THIS SETTLEMENT AGREEMENT AND RELEASE ("Settlement Agreement") is

[Attorney's Firm Name]

[Individual Passenger Bank Account Details]

5. Warranty of Capacity to Execute Agreement

6. Entire Agreement and Successors in Interest

7. Representation of Comprehension of Document

Dated: ________

Dated: _ __________

Dated: _ By:_________

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